A message from Immigration, Refugees and Citizenship Canada (IRCC) raises a concern about your application and gives you a date by which to reply. A procedural fairness letter, often shortened to PFL, means an officer has a specific concern and is giving you an opportunity to answer it before a decision is made. It is not a refusal, and not a decision at all.
The first instinct is to explain everything at once. Read the whole letter first. The concern it names, the response it asks for and the date it sets matter more than any sample letter found online.
What a procedural fairness letter is, and what it is not
Procedural fairness is a duty on the officer, not on you. IRCC’s guidance says an applicant must be given a fair and unbiased assessment, must be informed of the decision-maker’s concerns, and must have a meaningful opportunity to respond. The essence of those concerns must be communicated, and the applicant advised of the specific provisions of the Immigration and Refugee Protection Act at issue.
The letter is a map of the officer’s thinking: what is doubted, which section of the Act that doubt engages, and how long you have to answer. Officers must allow a reasonable opportunity to bring evidence or make arguments. If nothing arrives, the officer decides on the file as it stands.
A refusal is a later and different stage. If a decision has already been made on your file, our refusals and appeals page covers it.
Why an officer sends one
IRCC’s guidance names the situations that call for a letter: extrinsic evidence, which the officer must put to you; a concern arising from an interview; a change of decision-maker, where a new officer inherits the file and has to put the concerns to you; and a subjective assessment, such as credibility, made earlier in the file.
In practice the concern lands in a recognisable category: a document the officer cannot verify, an employment history that does not line up across forms, a relationship the officer is not satisfied is genuine, or a ground of inadmissibility. Build the response around that single question.
Read the exact concern before you reach for a template
Read for the precise issue. Is the letter asking about one document, an inconsistency between two, or part of the application history? Does it request named records? A working table helps you prepare for a review without guessing:
| Concern in the letter | Where it appears in the original application | Record available for review |
|---|---|---|
| Quote or summarise the wording accurately | File name and page reference | Who issued it, when, and where it is now |
Do not fill the table by guessing what the officer intended. Where the wording is unclear, mark it as a question for the consultation. Keep one clean copy of the letter. A reviewer needs the actual correspondence, attachments and instructions included, not a summary. A downloaded template cannot know which of your documents are verifiable or why two dates differ.
The original application matters as much as the new explanation
It is hard to remember exactly what was submitted many months ago. Find the submitted forms, the supporting documents and the confirmation records, including anything prepared by a previous representative. A document never submitted is a different problem from one submitted and read differently than you intended, and the response depends on which you have.
If part of the package cannot be located, say so. Do not rebuild a form from memory and label it as the version that was filed. Where a family or an employer holds different pieces, agree on plain file names: “submitted employment letter” beats “final”, “final2” and “new final”.
Evidence needs a source too. Note who issued each record, when, and how it answers the concern. Preserve the source material as it is: do not edit an employer’s letter, alter a bank record, or produce a replacement document that appears to have been issued earlier than it was.
When the concern is misrepresentation
The most serious version of a PFL raises section 40. Section 40(1)(a) makes a permanent resident or foreign national inadmissible for directly or indirectly misrepresenting or withholding material facts relating to a relevant matter that induces or could induce an error in the administration of the Act. Two words carry the weight: withholding reaches omissions as well as false statements, and could induce means no error need actually have occurred.
The consequence is statutory. Section 40(2)(a) provides that the person continues to be inadmissible for five years following, outside Canada, a final determination of inadmissibility, or, in Canada, the date the removal order is enforced, and section 40(3) bars an application for permanent resident status during that period. IRCC’s guidance states that an individual should always be given the opportunity to respond to concerns about a potential misrepresentation.
A letter citing section 40 is that opportunity, and it is the category where we would rather hear from you in the week the letter arrives than in the week it is due.
The deadline is the one in the letter
IRCC’s procedural fairness guidance sets no number of days. It requires a reasonable opportunity to respond, and the letter itself states the date. A document request in your account shows a “Required by” date, which IRCC describes as the deadline to send it. Figures quoted in news coverage or forum posts are not the rule for your file.
If you genuinely cannot obtain something in time, IRCC’s instructions are to explain why and include proof that you tried, through the channel the request specifies. Whether more time is given is the officer’s decision, and IRCC instructs you to send the document as soon as you have it even if it has not yet responded. Asking for more time does not move the date, and neither does gathering further records.
Submitting the response
Follow the instructions for your own file. IRCC’s instructions on submitting requested information set out the routes: the online account or portal where you were told to use it, its web form where you cannot use an account, and email, mail or fax where the request letter says so. Submitting through a route IRCC did not ask for can delay the application.
Keep the submission record. A finished document on your computer is not evidence that IRCC received it, and a screenshot of an account home page does not show which file was uploaded.
Who may prepare submissions for a fee is regulated. Section 91 limits paid representation and advice to a lawyer or paralegal in good standing with a provincial or territorial law society, a notary in good standing with the Chambre des notaires du Quebec, or a member in good standing of the College of Immigration and Citizenship Consultants (CICC), and IRCC lists the same three groups. Our guide to verifying a consultant’s licence shows how to check the register.
What can follow the decision
The officer weighs the response with the rest of the file and decides. Where an application is refused, IRCC now includes the officer’s decision notes with the refusal for most temporary resident applications, since 29 July 2025, and most permanent resident applications, since 26 May 2026, with portions removed in some cases to protect sensitive information. Our guide to IRCC refusal letters and officer decision notes covers how to read them.
A reconsideration request is one route. IRCC’s guidance says an officer must consider the request and decide whether to exercise discretion, that it should only be done in exceptional cases, that disagreement with the decision is not by itself exceptional, and that the onus is on the applicant.
Judicial review is another. Imprint does not provide Federal Court representation. If judicial review is being considered, obtain advice from a lawyer authorized to practise in that court.
A tribunal appeal exists only for particular decisions, not for every refusal. Section 63(1) lets a family class sponsor appeal a refusal to issue the permanent resident visa to the Immigration Appeal Division (IAD) of the Immigration and Refugee Board of Canada (IRB), within 30 days of the refusal letter according to the IRB. Section 64(3) removes that appeal where the decision rested on a finding of misrepresentation, unless the person sponsored is the sponsor’s spouse, common-law partner or child.
Edmonton, Calgary and Alberta
Imprint Immigration Services is an Edmonton practice at 300-9006 132 Avenue NW. Shirani Jenita Daniel, RCIC-IRB, CICC Licence R705794, is a regulated immigration consultant authorized before IRCC and before all four divisions of the IRB, and reviews immigration matters within that authorized scope. Clients in Calgary and elsewhere in Alberta work with us by video, and IRB hearings are commonly held by video. Because a PFL carries a date, the first conversation is often in the week the letter arrives.
Book a consultation
For a procedural fairness consultation, have the letter, the original application package, the related correspondence and a short list of records you can obtain. Give the stated deadline when you book so the timing can be assessed. Booking a consultation does not extend an IRCC deadline and does not by itself mean representation has begun. A 30-minute consultation is $50 plus 5% GST, by video or in person, from our Edmonton practice. Book a consultation. Because these letters are time-critical, you can also call (825) 435-1101 or email info@imprintimmigration.com.
No. The two documents serve different purposes and sit at different stages. A procedural fairness letter tells you an officer has a concern and gives you an opportunity to respond before a decision is made. A refusal is a decision that has already been made. Read the actual correspondence to establish which stage your file has reached, rather than relying on the email subject line.
The letter sets the date. IRCC’s procedural fairness guidance does not fix a number of days; it requires a reasonable opportunity to respond, and a document request in your account shows a “Required by” date, which IRCC describes as the deadline. Read the letter the day it arrives and work backwards from that date. Figures quoted in news coverage or forum posts are not the rule for your file.
A sample can show you a format. It cannot establish the facts or the evidence your own file needs. The response has to address the concern actually raised, against what was actually submitted. A template cannot know which of your documents are verifiable, what the original application said, or why two dates differ, and confident wording does not answer an evidence problem.
Section 40 of the Immigration and Refugee Protection Act makes a person inadmissible for misrepresenting or withholding material facts. Section 40(2)(a) provides that the inadmissibility continues for five years following a final determination where it was made outside Canada, or the date a removal order is enforced where it was made in Canada. Section 40(3) provides that the person may not apply for permanent resident status during that period.
Section 91 of the Act limits paid representation and advice to a lawyer or paralegal in good standing with a provincial or territorial law society, a notary in good standing with the Chambre des notaires du Quebec, or a member in good standing of the College of Immigration and Citizenship Consultants. IRCC lists the same three groups. Anyone else charging you to draft a response is not authorized to do it.
Only for particular decisions. Section 63(1) lets a family class sponsor appeal a refusal to issue the permanent resident visa to the Immigration Appeal Division, and the IRB says the notice of appeal must reach the IAD within 30 days of the refusal letter. Section 64(3) removes that appeal where the finding was misrepresentation, unless the person sponsored is a spouse, common-law partner or child.
Official sources
- IRCC program delivery instructions: Procedural fairness
- Immigration and Refugee Protection Act, section 40 (misrepresentation)
- IRCC program delivery instructions: Misrepresentation
- IRCC: Submit requested information and documents
- IRCC: Officer decision notes
- IRCC program delivery instructions: Reconsideration after refusal
- Immigration and Refugee Protection Act, section 63 (right to appeal)
- Immigration and Refugee Protection Act, section 64 (no appeal for inadmissibility)
- Immigration and Refugee Protection Act, section 91 (representation or advice for consideration)
- IRCC: Learn about representatives
- IRB: File your notice of appeal (sponsorship appeal)
Checked against the official source on 27 September 2026. Immigration rules change. Where this page and an official page disagree, the official page is correct.
This article is general information and is not immigration advice. Advice about your own situation comes from a consultation with Shirani Jenita Daniel, RCIC-IRB, CICC Licence R705794. Representation begins only once a retainer is signed.
Written by
Shirani Jenita Daniel, RCIC-IRB
CICC Licence R705794 · Commissioner for Oaths (Alberta) · Founder, Imprint Immigration Services Inc.



